California Privacy Policy - Ironwood Pharmaceuticals

NOTICES

Notice at Collection for Candidates & Employees

We may collect the following categories of personal information about you in connection with your employment or application for employment: identifiers, demographic information, professional and employment-related information and qualifications, education information, sensitive personal information (including Social Security number, race, ethnic origin), and inferences drawn from the above-listed categories of personal information. We also may collect these additional categories of personal information during the course of your employment: financial information, Internet or other electronic network activity information (for example, when you use company-owned IT resources) geolocation data (such as when you use a company-owned vehicle or device), and audio, electronic, visual, thermal, olfactory, or similar information (such as your photograph).

Ironwood collects and uses your personal information, including your sensitive personal information, solely in connection with administering the employment relationship (such as providing benefits, payroll, performance reviews, permitting access to Ironwood facilities and resources) or evaluating your application for employment (such as screening applicants, determining employment eligibility, conducting interviews, and negotiating an employment offer). Ironwood does not “sell” or “share” your personal information, as those terms are defined by the California Privacy Law.

We will retain your personal information for as long as necessary to satisfy the purposes for which we collected it, including to evaluate your candidacy or administer the employment relationships, as well as to comply with any applicable legal, accounting, or reporting requirements; to establish, exercise, or defend legal claims; or for our legitimate purposes. Requests to delete your personal information are subject to these obligations and restrictions.

Applicants should know that, to submit your application, you may be interacting with us through a third-party application platform, such as Greenhouse, ADP, EBI or LinkedIn, which Ironwood does not control. Before proceeding, you should review the privacy policies published by these third parties to understand how they will handle your personal information. information.

Notice at Collection for Website Visitors and Other Consumers

We may collect the following categories of personal information from you in connection with your use of our website or other interaction with our us and our products: identifiers, demographic information, commercial information, internet or other electronic network activity information (e.g., internet browsing history, search history, intranet activity, email communications, social media postings), and audio, electronic, visual or similar information (such as calls that are recorded for quality assurance purposes), and inferences drawn from the PI in the categories above.

Ironwood collects and uses your personal information for its business purposes, as detailed in Section 5 of this California Consumer Privacy Policy. These business purposes may include communicating with you, providing marketing communications or other promotional programs, delivering our products, evaluating your eligibility for relevant programs (e.g., patient savings programs), developing our business relationship with you, research and development (e.g., for a clinical trial), product safety, and website administration, analytics, and improvement.

Ironwood does not “sell” or “share” your personal information, as those terms are defined by the California Privacy Law.

We will retain your personal information for as long as needed to satisfy the purposes for which we collected it, to comply with any applicable legal, accounting, or reporting requirements; to establish, exercise, or defend legal claims; or for our legitimate purposes.

For more information about Ironwood’s privacy practices, please see the Ironwood Privacy Policy.

California Consumer Privacy Policy

1.0 Purpose

Ironwood Pharmaceuticals, Inc., (“Ironwood,” “we,” “us”) is committed to safeguarding the privacy of your personal information. This California Consumer Privacy Policy (“Policy”) describes how we collect, use, and disclose personal information about you. This Policy also describes rights you have in connection with our use of your personal information. But first please know that Ironwood does not “sell” or “share”  your personal information with third parties, as those terms are specially defined by California Privacy Law (as defined below). Personal information is information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your household.

This Policy contains disclosures required by the California Consumer Privacy Act (“CCPA”), as amended by the California Privacy Rights Act (“CPRA”) (together, “California Privacy Law”), and supplements and amends the information contained in Ironwood’s Privacy Policy with respect to individuals, visitors, users, and others who are natural persons and residents of the State of California (collectively, “California Residents”). Any terms defined in California Privacy Law have the same meaning when used in this Policy.

This Policy applies to the operation of our website, www.ironwoodpharma.com, and other applications under our control (including mobile applications) (collectively the “Site”) as well as our collection of personal information through other channels, whether online or offline. Our Site may contain links to websites operated by Ironwood’s product co-promotion and co-marketing partners or other third parties. Your interaction with any websites operated by such partners are governed by the privacy policies posted on those websites. We do not control, nor are we responsible for, third parties’ privacy practices.

2.0 Your Rights Under California Privacy Law

As a California Resident you may have rights under California Privacy Law, which may include, subject to exceptions:

Your Right to Access
You may be entitled to request that we disclose to you the specific pieces of personal information we have collected about you in a portable, and to the extent technically feasible, readily usable format.

Your Right to Know:
You have a right to request to know:

The categories of personal information Ironwood has collected about you;

The categories of places or sources where Ironwood got your personal information;

The business reason why Ironwood collects your personal information;

The categories of personal information we disclose for a business purpose; and

The types of companies or people that we share or disclose your personal information with.

Your Right to Ask Ironwood to Delete Your Personal Information
You have the right to ask us to delete personal information that we have about you. We will use commercially reasonable efforts to honor your request, in compliance with applicable laws, and may also direct any service providers with which we have shared your personal information to delete your personal information from their records, as well.

Your Right to Correct Your Personal Information
You may also have the right to request that we update inaccurate information that we process about you. We will use commercially reasonable efforts to honor your request, in compliance with applicable laws.

Right to Limit Use of Your Sensitive Personal Information
You are entitled to limit use and disclosure of your sensitive personal information to certain business purposes.

Your Right to Exercise Rights Without Discrimination
You have the right not to receive discriminatory treatment if you exercise the rights conferred to you by applicable law.

There are three ways you can exercise these rights (or contact us):

You can call us at 1-844-374-4793

You can email us at [email protected]

You can send a letter to us at this address: Ironwood Pharmaceuticals, Inc.
Attn: Privacy Officer
100 Summer Street
23rd Floor
Boston, MA 02110

We will confirm your request within 10 days of receipt, and we will respond to your request within 45 days (or 90 days, where extenuating circumstances permit an extension). If we are not able to honor your request, we will let you know why. For example, there may be a law that we have to follow that won’t permit us to delete your personal information.

Please note that we may require additional information from you to verify your identity and process a request to exercise your rights under this Policy. If we request, you must provide us with sufficient information to verify your identity and/or authority to act on behalf of the consumer when submitting a request. In general, we may ask you to provide identifying information that we already maintain about you or we may use a third-party verification service. In either event, we will try to avoid asking you for sensitive personal information to verify your identity. We may not be able to respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. However, making a verifiable consumer request does not require you to create an account with us. Additionally, you will need to describe your request with sufficient detail to allow us to review, understand, assess, and respond. personal information collected from an individual to determine whether a request is a verifiable consumer request may not be used or disclosed for any other purpose except as required by law.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Any disclosures we provide in response to a request to know will only cover the 12-month period preceding the receipt of your verifiable consumer request, unless a longer lookback period is required by law. The response we provide will also explain the reasons we cannot comply with a request, if applicable.

3.0 What Categories of Personal Information May Ironwood Collect?

We may collect (or may have collected in the preceding 12 months), the following personal information about you based on your interactions with us:

Identifiers, such as your name, address, telephone number, mobile number, email address, driver’s license or state identification number, and other similar contact information and identifiers.
Financial information, such as your bank account information.
Demographic information, such as protected classifications under California or federal law, which may include age, date or birth, or gender.
Commercial information, such as products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

Internet or other electronic network activity information, including but not limited to all activity on the Company’s information systems, such as internet browsing history, search history, intranet activity, email communications, social media postings, stored documents and emails, usernames and passwords; all activity on communications systems including phone calls, call logs, voice mails, text messages, chat logs, app use, mobile browsing and search history, mobile email communications, and other information regarding an employee’s use of company-issued devices.
Professional and employment-related information and qualifications, including without limitation:

data submitted with employment applications including salary history, employment history, and employment recommendations;
background check and criminal history;
work authorization;

fitness for duty data and reports;
performance and disciplinary records;
salary and bonus data, where permitted by law;
benefit plan enrollment, participation, and claims information;
leave of absence information including religious and family obligations, physical; and mental health data concerning employee and his or her family members.

Education information, such as education history.
Geolocation data, such as GPS location data from company-issued mobile devices or vehicles.
Audio, electronic, visual, thermal, olfactory, or similar information.
Sensitive personal information, such as your Social Security number, driver’s license or state identification number, and your racial or ethnic origin.
Inferences drawn from the PI in the categories above.

4.0 How Does Ironwood Get Your Personal Information?

We collect personal information directly from you that you submit to us. We will ask you for personal information when you interact with us, using any interactive features or applications, signing up to receive a newsletter, participating in an incentive or savings program, contacting us to ask questions, doing business with us, or seeking or maintaining employment or an internship with us.

We also may collect additional information about you automatically when you visit the Site, such as through cookies, pixels, and other tracking technologies. You may refuse the use of cookies by selecting the appropriate settings on your browser, however, please note that if you do this you may not be able to use the full functionality of our Site. The Site does not respond to “Do Not Track” signals sent by Internet browsers, unless or until required by law. We also may collect personal information about you from things like public records, or from social media sites such as Facebook. In addition, we may receive your personal information from companies that provide us with services or who help us provide services to you. We treat this data as personal information only when it, or other data that is associated with it, can be used to identify you.

5.0 Why Does Ironwood Collect and Use Your Personal Information?

Ironwood collects and uses your personal information for its business purposes, such as:

Responding to your requests for information, products, services, including managing your online accounts with us;
Providing you with general health information (such as information on certain health conditions) as well as information about our products and services;
Providing you with marketing communications and offers for products and services;
Delivering our products;

Running promotional programs, such as sweepstakes, rewards, and rebate programs;
To determine if you are eligible for certain products, services, or programs (such as patient savings programs);
If you have a business or professional relationship with Ironwood, to develop our business relationship with you;
If you apply for a job via our career center, to consider you for employment;
For our research and development efforts, like clinical studies in which you may be interested;

To monitor and analyze our business operations and website and other applications usage;
To make your data anonymous so that it is no longer personal information;
For product safety reasons such as side effect (adverse event) reporting, product complaint reporting, or to communicate product safety information to you;
To verify such things as professional status, identity and specialty when providing information, communications or products/and or services to doctors and other healthcare professionals; and
For other everyday business purposes, such as payment processing and financial account management, product development, contract management, website administration, fulfillment, analytics, fraud prevention, corporate governance, reporting, and legal compliance.

Sensitive personal information is only used to manage our employment or other contractual working relationship and fulfill our duties as an employer. We do not use or disclose your sensitive personal information except as stated in this Policy or otherwise permitted by California Privacy Law.

We reserve the right to use de-identified or aggregated data for any purpose and without limitation, and we will not attempt to re-identify the information.

6.0 Who Do We Share Your Personal Information With?

As a reminder please know that Ironwood does not sell your personal information and that we have not sold any personal information in the past 12 months. In addition, we do not share or distribute your personal information with any other company for their marketing purposes. We may share your personal information with the following categories of third parties for the purposes described above:

We may share your personal information with your consent or as you direct. For example, we may share data with your doctor as part of programs in which you agree to participate.

We may share your personal information with our affiliated companies, product co-promotion and co-marketing partners, which may only use your personal information for the purposes as we have agreed to.
We may share your personal information with companies that provide services to us like health insurance companies or payroll companies. These companies are bound by law or contract to protect your personal information and only use your personal information the way we tell them to.
We may also disclose your personal information where needed to sell or transfer business assets, to investigate legal issues, enforce our rights, protect our property, or protect the rights, property or safety of others, or as needed support external auditing, compliance and corporate governance functions.
We may also disclose your personal information if required by law, such as in response to a subpoena, or to comply with requirements of law enforcement agencies and courts in the United States and other countries where we operate.
Please note that we may also disclose data about you that is called “de-identified” or “aggregated” data. This type of information does not identify who you are so it is not personally identifiable. For example, we may publish reports that contain aggregate and statistical data about our customers. These reports do not contain any data that would let somebody contact, locate, or identify you.

In the preceding 12 months, we have disclosed personal information for our business purposes. With respect to each category of personal information we collect (see Section 3 above), we disclose such personal information to our service providers, including our IT, HR, financial, and commercial (analytics, marketing) vendors. Note, however, that we do not share any employment-related personal information with our commercial vendors.

7.0 Data Security & Retention

Ironwood employs reasonable physical, technical, and administrative safeguards to protect personal information from unauthorized access, disclosure, use, loss, misuse, or unauthorized alteration, or destruction. Please note, however that, notwithstanding these safeguards, it is impossible to guarantee 100% security in all circumstances.

8.0 Authorized Agents

If you would like, you can empower someone else (an “Authorized Agent”) to exercise your rights under this Policy on your behalf. If your Authorized Agent sends us a request to exercise your rights under this Policy, we may: (i) ask that person to provide written proof that you gave that person permission to make the request on your behalf; (ii) seek to verify your identity directly; and/or (iii) ask that you confirm the Authorized Agent’s authority. If we do not receive this information, we may deny their request so that we can protect your personal information.

9.0 Children’s Privacy

The Site is not directed at children under the age of 16, and we do not knowingly collect any personal information of anyone under the age of 16. We also do not knowingly disclose personal information about children under the age of 16 to third parties for monetary or other valuable consideration (i.e., “sell” or “share,” as those terms are defined in California Privacy Law).

If you believe your child is using our website, please contact us using one of the three ways listed in Section 2 of this Policy. We will delete any information we have collected or received from a child under the age of 16 without verification of parental consent.

10.0 Ironwood’s General Privacy Policy

For more information about Ironwood’s Privacy Policy, please click this link Ironwood Privacy Policy.

11.0 Updates to this Privacy Policy

We may update this Policy to reflect changes in the ways we collect, use, and disclose personal information, or in applicable law. When we update this Policy, we will indicate when it was most recently updated by noting that date in this Policy. Should we make a material change to this Policy, we may provide you with notice prior to the update going into effect, including by posting a conspicuous notice on our Site. Unless otherwise indicated, revisions to this Policy are effective immediately upon posting. 

Last Updated Date: June 16, 2023